Initiated By
FINRA
Allegations
FINRA RULE 2010:
WHILE REGISTERED WITH HIS MEMBER FIRM AND IN ANTICIPATION OF HIS MOVE TO A NEW FIRM, PERRY MOVED DOCUMENTS RELATED TO FIRM CUSTOMERS HE SERVICED FROM HIS FIRM OFFICE TO HIS HOME. THE DOCUMENTS CONTAINED NONPUBLIC PERSONAL INFORMATION, AS THAT TERM IS DEFINED UNDER REGULATION S-P OF THE SECURITIES EXCHANGE ACT OF 1934, AND PERRY MOVED THEM WITHOUT THE AUTHORIZATION AND IN CONTRAVENTION OF HIS FIRM'S POLICIES. AMONG OTHER THINGS, THE NONPUBLIC PERSONAL INFORMATION INCLUDED CUSTOMERS' ASSET AND INCOME INFORMATION, HEALTH INFORMATION, ADDRESSES, BIRTHDATES, AND EMPLOYMENT INFORMATION. BY REMOVING THE CUSTOMERS' FILES FROM HIS FIRM'S CONTROL AND POSSESSION, PERRY PLACED THE CUSTOMERS' NONPUBLIC PERSONAL INFORMATION AT RISK.
Resolution
Acceptance, Waiver & Consent(AWC)
Sanctions
Civil and Administrative Penalty(ies)/Fine(s)
Amount
$5,000.00
Sanctions
Suspension
Registration Capacities Affected
ANY CAPACITY
Duration
FIVE BUSINESS DAYS
Start Date
12/2/2013
End Date
12/6/2013
Regulator Statement
WITHOUT ADMITTING OR DENYING THE FINDINGS, PERRY CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE HE IS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR FIVE BUSINESS DAYS. THE SUSPENSION IS IN EFFECT FROM DECEMBER 2, 2013 THROUGH DECEMBER 6, 2013. FINE PAID IN FULL ON NOVEMBER 22, 2013.
Broker Comment
WITHOUT ADMITTING OR DENYING THE FINDINGS, PERRY CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. THEREFORE, HE WAS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR FIVE BUSINESS DAYS. THE SUSPENSION IS IN EFFECT FROM DECEMBER 2, 2013 THROUGH DECEMBER 6, 2013.